IN THE UNITED STATES DISTRICT
COURT FOR THE
WESTERN DISTRICT OF MISSOURI
WESTERN DIVISION

UNITED STATES OF AMERICA

Plaintiff,

v.

NO. _____

JACKIE UPTEGROVE,

29 U.S.C. § 439(c)

Defendant.

NMT: One Year Imprisonment,
NMT: $10,000 Fine,
NMT: One Year Supervised Release
Class A Misdemeanor
$50 Mandatory Special Assessment

INFORMATION

The United States Attorney charges:

COUNT ONE

Between on or about January 1, 2004, and
December 31, 2004, in the Western District of Missouri, JACKIE UPTEGROVE, defendant
herein, did knowingly and willfully make false entries in records, reports,
and statements of Local M-146, International Brotherhood of Boilermakers, Iron
Ship Builders, Blacksmiths, Forgers and Helpers, AFL-CIO, in that defendant
willfully made and submitted false "lost time" vouchers to conceal his embezzlement
of union funds which he converted to his own use, and which records, reports,
and statements, Local M-146, International Brotherhood of Boilermakers, Iron
Ship Builders, Blacksmiths, Forgers and Helpers was required to keep and maintain
pursuant to the provisions of Title 29 of the United States Code.